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HMRC internal manual

Business Leasing Manual

HM Revenue & Customs
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‘Income-into-capital’ schemes and back dated leases: Back loaded leases: period of account

‘Period of account’ is defined as a period for which accounts are made up. For the purpose of CTA10/S928 it does not include any period prior to 26 November 1996 (CTA10/S937). This ensured that the charge was not imposed retrospectively for periods prior to the announcement of those measures on Budget Day (26 November) 1996. By contrast, for the purpose of determining whether a lease comes within Chapter 2 of Part 21 of CTA 2010 in the first place, there is no such restriction (see BLM70420)